Opening corporate bank accounts in Vietnam: the payment account rules, verification of the legal representative, documents, beneficial ownership and source-of-funds checks, signatories, foreign-currency accounts and choosing a bank

The accounts a foreign-invested company needs

A Vietnamese company with foreign capital usually holds at least three accounts. The investment capital account carries capital contributions, share-transfer payments with Vietnamese parties, profit remittance and the return of capital; it is held at one bank, one account per currency, and is explained in The investment capital account. A dong payment account carries the business: sales receipts, supplier payments, payroll, social insurance contributions and tax. A foreign-currency payment account receives export proceeds and other foreign-currency income that the company may lawfully receive and pays foreign suppliers and group companies. A company that borrows abroad may also need a dedicated foreign loan account (Offshore loans and State Bank registration).

Payment accounts may be held at more than one bank, and many companies keep a second bank for resilience or for a particular product, for example a local bank with a wide branch network for payroll and a foreign bank for treasury and cross-border payments. The investment capital account, by contrast, is held at only one bank, so the choice of that bank deserves more thought. Most companies keep the investment capital account and the main payment accounts at the same bank, so that the bank sees the whole history of the capital it will later remit.

The legal framework

Payment accounts are governed by Circular No. 17/2024/TT-NHNN on the opening and use of payment accounts, in force since 1 January 2025, as amended by Circular No. 25/2025/TT-NHNN of 31 August 2025. The amending circular took effect on the date it was issued, with some provisions applying from 1 December 2025 and the rules on account names from 1 March 2026. The circulars sit within Decree No. 52/2024/ND-CP on non-cash payments and Law No. 32/2024/QH15 on Credit Institutions, and banks apply them together with Law No. 14/2022/QH15 on Anti-Money Laundering and Decree No. 19/2023/ND-CP. The investment capital account follows the same general opening rules, plus the specific rules in Circular No. 38/2026/TT-NHNN.

Verifying the legal representative

The most significant change of recent years is the requirement that the bank verify the company's legal representative in person. As amended by Circular No. 25/2025/TT-NHNN, the circular requires the bank, for an organisation, to meet the lawful representative of the account holder in person and verify his or her information, including by matching biometric data against the identity document where the document type allows. For a foreign legal entity, a third party or contracted organisation may carry out the meeting and the biometric matching on the bank's behalf. The bank must store the representative's biometric data and the results of the comparison securely.

For a foreign national legal representative, the identity document is the passport or another identity document issued by a competent foreign authority; a foreigner resident in Vietnam must also produce an entry visa, a valid document in lieu of a visa or proof of visa exemption. Banks' remote biometric processes are often built around Vietnamese chip-based citizen identity cards, so a foreign legal representative should expect to complete verification at a branch.

The consequence of missing verification is practical rather than theoretical. Since 1 July 2025 banks have suspended online payments and withdrawals on corporate accounts whose legal representative has not completed biometric verification; the account stays open, but the company cannot use internet banking for outgoing payments until the representative attends. A change of legal representative triggers the same requirement for the new representative, so the change should be planned around a visit to the bank (Legal representative and governance).

Electronic opening

The circular permits accounts to be opened electronically, and organisations are not excluded from electronic opening. Where an organisation uses an electronic identification account under the national electronic identification system, the bank may not ask for information that is already contained in it. In practice, for a newly established foreign-invested company with a foreign legal representative, banks generally still require at least one in-person meeting, and the investment capital account in particular is usually opened at a branch with original documents. Electronic opening is more useful for a second payment account at an existing bank, or for a company whose representative already holds Vietnamese electronic identification.

Beneficial ownership and source of funds

Under Law No. 14/2022/QH15 the bank must identify the customer and its beneficial owners, the individuals who ultimately own or control it, and verify their identity using reliable sources. Circular No. 25/2025/TT-NHNN expressly adds the anti-money-laundering identification documents to the account-opening dossier for organisations. The bank will compare what it receives with the beneficial ownership information the company filed on registration under the Law on Enterprises (Beneficial ownership and transparency), so the two must match.

For a foreign-invested company the bank will usually ask for a group structure chart running from the Vietnamese company up to the ultimate individual owners or a listed parent, identity documents for each individual beneficial owner above the bank's threshold, and an explanation of the source of the capital to be contributed. For a subsidiary of a listed group the explanation can be short; for a company owned by individuals through holding companies in several jurisdictions the bank may ask for audited accounts, bank statements or tax returns of the holding entities. Vietnam's place on the FATF increased-monitoring list has made these requests more thorough, and banks may decline relationships they consider high-risk without giving detailed reasons.

Opening the accounts, step by step

1. Choose the bank before the ERC issuesApproach two or three banks while the company is being registered, obtain their account-opening checklists, and confirm that they open investment capital accounts before the IRC if the company-first route is used.
2. Prepare the ownership and source-of-funds packGroup chart to the ultimate individual owners, identity documents of beneficial owners, parent's certificate of incorporation and latest accounts, and a short note on the source of the capital and expected payment flows.
3. Assemble the company documentsERC, IRC where issued, charter, decision appointing the legal representative and chief accountant, members' or board resolution approving the accounts and signatories, and the company seal if one is used.
4. Book the legal representative's visitSchedule an in-person meeting at the branch for identity and biometric verification; a foreign representative brings the passport and, if resident, the visa, temporary residence card or exemption evidence.
5. Sign the account agreements and specimen signaturesComplete the account application forms, specimen signatures of the legal representative, the chief accountant and any authorised persons, and the internet banking and token arrangements.
6. Open the investment capital account firstSo that the charter capital can be remitted inside the 90-day window; then the dong and foreign-currency payment accounts.
7. Activate online banking and testConfirm that biometric status is recorded, set up approval levels for payments, and make a small test transfer before the first capital remittance.
8. Link the accounts to e-tax paymentRegister the payment account for electronic tax payment and check with the tax adviser whether the account details must be notified as part of the company's tax registration information; see Setting up a company step by step.

Signatories and internal controls

The account holder acts through its legal representative or a person the legal representative authorises in writing within the scope permitted by law. Banks commonly require payment instructions for an organisation's account to carry the signature of the account holder's representative and, where the company is required to have one, the chief accountant or the person in charge of accounting, whose documents are now part of the account-opening dossier under Circular No. 25/2025/TT-NHNN. Internet banking is set up with a maker and approver structure, and the approver's token or digital signature is tied to the verified individual.

Foreign groups often want offshore approval of large payments. That is achievable through internal controls, for example an approval workflow in which the regional treasury approves before the Vietnamese approver releases, but the bank mandate itself must be given by the Vietnamese company through its legal representative. A legal representative who leaves Vietnam for long periods, or who resigns without a planned handover, can freeze the company's outgoing payments; at least one legal representative must reside in Vietnam under the Law on Enterprises.

Foreign-currency accounts

A resident company may open foreign-currency payment accounts at an authorised bank and may receive into them foreign currency it is permitted to receive: export proceeds, payments from non-residents for services, foreign-currency loan drawdowns where permitted, and transfers from its investment capital account. It may use them to pay non-residents for imports and services and to make other permitted payments. It may not use them to pay other residents except where Circular No. 32/2013/TT-NHNN permits, for example to an export processing enterprise, or to pay foreign employees' salaries in foreign currency (Currency and payments inside Vietnam). Export proceeds in foreign currency are brought into the company's foreign-currency account in Vietnam; residents need State Bank approval to hold accounts abroad, save for limited cases.

Timelines and choice of bank

With a complete dossier and a legal representative who can attend, a payment account is commonly opened within a few working days of the meeting, and the investment capital account within about one to two weeks. Delays almost always come from the anti-money-laundering review: a complex ownership chain, an individual beneficial owner in a jurisdiction the bank considers high-risk, or a source-of-funds explanation the compliance team wants supported. Allowing four weeks from first approach to activated online banking is prudent, and the timetable should be measured against the 90-day charter capital deadline.

The choice is usually between a large Vietnamese commercial bank and a wholly foreign-owned bank or foreign bank branch. Vietnamese banks offer extensive branch and ATM networks, competitive dong pricing, strong payroll and tax-payment products and familiarity with provincial authorities. Foreign banks, such as the Vietnamese subsidiaries of HSBC, Standard Chartered, Shinhan and UOB, offer English-language service, integration with the group's global banking relationship, and experience with cross-border payments and capital-account flows; their onboarding is often more demanding because group policies sit on top of Vietnamese law. Many investors use a foreign bank for the investment capital account and treasury and a Vietnamese bank for local payments.